1. Who We Are
MANA³ is a practitioner-facing coherence and performance tracking platform operated by Maxime Fréchet, based in Geneva, Switzerland. We process health and wellness data on behalf of practitioners and their clients to generate longitudinal coherence reports.
Data Controller: Maxime Fréchet, MANA³
Contact: maxime-frechet@mana-cubed.com
Location: Geneva, Switzerland
2. What Data We Collect
We collect and process data from three sources, corresponding to our three-tier data architecture: wearable devices (Garmin, Polar, Oura), practitioner assessments, client check-ins, and account information.
3. Why We Process Your Data
Coherence tracking and reporting: To generate longitudinal coherence reports that track how a client's physiological systems interact and evolve over time.
Practitioner intelligence: To provide practitioners with data-driven insights that support their clinical decision-making.
Platform operation: To maintain client accounts, synchronize wearable data, process daily check-ins, and deliver reports.
4. Legal Basis for Processing
Explicit consent (Art. 9(2)(a) GDPR): Health data is classified as a special category of personal data. We process this data only with the client's explicit, informed consent.
Contractual necessity (Art. 6(1)(b) GDPR): Processing of account information is necessary to provide the MANA³ service.
5. Wearable Device Data
MANA³ integrates with wearable device platforms including Garmin, Polar, and Oura. When a client connects their wearable device, they authorize the device manufacturer to share their data with our platform. This authorization can be revoked at any time.
We do not sell, share, or transfer wearable device data to any third party.
6. AI and Data Processing
MANA³ uses an AI-assisted narrative engine to generate interpretive reports. The AI receives pre-computed numerical scores, not raw API data. No client data is used to train, fine-tune, or improve any external AI or LLM model. All scoring is deterministic.
7. How We Store Your Data
Client data is stored in a secure database with access restricted to the assigned practitioner and the MANA³ platform. Data is encrypted in transit (TLS/SSL) and at rest where supported.
8. Who Has Access to Your Data
Access is strictly limited to your assigned practitioner and the MANA³ platform. We do not share your data with advertisers, data brokers, research institutions, or any other third party.
9. Data Retention
We retain your data for as long as you are an active client. If you terminate the service, we will delete your personal and health data within 30 days of receiving a deletion request.
10. Your Rights
Under the GDPR and Swiss nFADP, you have the right of access, rectification, erasure, data portability, withdrawal of consent, and the right to lodge a complaint with a supervisory authority.
11. International Data Transfers
MANA³ operates from Switzerland, which benefits from an EU adequacy decision for data protection.
12. Changes to This Policy
We may update this privacy policy from time to time. Any significant changes will be communicated to active clients and their practitioners.